On 14 November 2016, HM Revenue and Customs Permanent Secretary and Executive Chairman Edward Troup and the Swiss Ambassador to the United Kingdom, Dominik Furgler, signed an agreement ending the tax cooperation agreement between Great Britain and Switzerland. The initial tax agreement between the United Kingdom and Switzerland was signed on 6 October 2011 by Finance Minister David Gauke and Swiss Finance Minister Eveline Widmer-Schlumpf. In Switzerland, there is no interest-rate WHT from regular loan contracts. Swiss WHT of 35% is levied only on interest paid by banking institutions (or by companies that are tax-qualified as “banks”) to non-banks, interest on bonds and interest on bond-like loans. The residual rates in the table below indicate standard contract rates and do not reflect other facilities available in some TDS (. B, for example, for traded bonds or other traded securities). On 6 October 2011, the United Kingdom and Switzerland signed and published the text of their tax agreement for UK residents with accounts in Switzerland (the “agreement”). The publication of the agreement is good news, as it provides a welcome clarification on a number of issues that (as noted in our previous Stop Press of 13 September 2011) were not clear from the previously published information. On the other hand, it also confirmed that the agreement had some important restrictions. The United Kingdom has concluded a series of bilateral tax cooperation agreements through the exchange of information. On 20 March 2012, the United Kingdom and Switzerland signed a protocol to the tax treaty. See the main part of the cooperation agreement between the UNITED Kingdom and Switzerland: tax cooperation agreement for the comprehensive whistleblowing agreement.
The initial agreement is also available. HMRC has reached an agreement with the Swiss tax authorities. The agreement allows for close cooperation between the UK and Switzerland, and there is an important exchange of information between the two countries. The agreement provides for a historic tax on Swiss funds held by residents in the UK, up to 34% of the balance in an account as of 31 December 2010 or 31 December 2012. UK residents with Swiss accounts may also be subject to a WHT of up to 48% on their accounts. With regard to inheritance tax, Swiss payers are required to withhold 40% tax or to file a declaration if a person dies, as well as other measures. The United Kingdom and Switzerland have signed the Common Reporting Standard of the Organisation for Economic Co-operation and Development: a comprehensive agreement on the annual and automatic transfer of financial account data.